Privacy Policy
United Trust Limited Privacy Policy
How we protect your privacy 1. Introduction
Protecting your right to privacy and ensuring the confidentiality of your personal information is fundamental to the way United Trust Limited (the Bank) does business. As a banking and financial services organisation, we are committed to handling your personal information confidentially. We treat the ongoing trust that you have in us to protect your personal information confidentially. We treat the ongoing trust that you have in us to personal information very seriously. We have procedures and robust systems in place to protect your privacy whenever we collect, store, use or disclose your personal information. You can request details about the information the Bank holds about you and you have a right to ask us to correct this information.
The privacy framework The Privacy Act 1988 (Commonwealth) and the ten National Privacy Principles (NPPs) set out in that Act regulate the way private sector organisations, including the Bank, handle personal information. The NPPs came into effect on 21 December 2001.
The United Trust Privacy Policy The United Trust Privacy Policy explains how we protect your privacy, including:
- how we respect your privacy in the course of using your personal information; and
- the importance of your consent before we disclose your personal information to third parties.
2. Collecting your personal information
We collect your personal information only when it is necessary to perform our functions or activities; for example, opening and operating a bank account.
We collect most personal information directly from you. For example, we may collect personal information when you open an account, fill in an application form, deal with us over the telephone, send us a letter, visit our web site, or when you have contact with us in person. The type of personal information we collect always includes your name and may include your mailing address, telephone number, e-mail address, tax file number, date of birth, annual income and other financial details, place of work, credit history and transaction history.
There may be occasions when we need to source personal information about you from a third party. For example, we may collect personal information from a credit reporting agency or an insurer of your mortgage.
Your sensitive information Without your consent, we will not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, political or religious affiliations, membership of a trade or professional association or trade union, sexual preferences or practices, criminal record, or health information. This is subject to some exceptions, including where the collection is required by law or for the establishment, exercise or defence of a legal claim.
3. Using your personal information
In addition to using your personal information for one of our primary purposes, we may also use or disclose your personal information for purposes related or ancillary to the main reason we collect it, such as:
- helping us to identify and advise you about other services or products that may be of benefit to you;
- enhancing and supporting our relationship with you;
- legislative and regulatory reporting and compliance;
- internal accounting, administration, risk management, record keeping, archiving, systems development and testing, credit scoring and staff training; and
- protecting you and the Bank from error, crime or fraud.
We may contract out some of our functions and activities; for example, we may provide names and addresses to a mailing house to enable them to mail account statements to you. In these situations, we prohibit the third parties from using your personal information except for the specific purpose for which we have supplied it.
Our duty of confidentiality We have a duty to keep all personal information we hold about you confidential, including:
- your name, address, and financial information;
- the credit or debit balance in your account; and
- any details of transactions that appear on your account.
Our duty of confidentiality applies except where the disclosure of your personal information is:
- with your consent
- compelled by law
For example, disclosure to various Government departments and agencies such as the Australian Taxation Office, and disclosure to courts under subpoena.
- in the public interest
For example, where a fraud, crime or misdeed is committed or is suspected, and disclosure against the customer ’s rights of confidentiality is justified.
- required in legal proceedings
For example, disclosure to a court in the event of legal action to which the Bank is a party.
- a permitted secondary disclosure
For example, the Bank may disclose your personal information to a third party in order to conduct a credit reference check.
Your consent is important
Your consent can either be express or implied. Your express consent can be written or verbal. For example when you sign an application for a loan, you are giving your express consent for us to obtain a credit reference about you from a credit reporting agency because our loan application contains a statement that a credit reference will be obtained. You imply consent when we can reasonably conclude that you have given consent by some action you take, or when you decide not to take action. For example, if you hear a recorded message telling you that the call may be monitored or recorded for training purposes and you do not indicate your objection to this, you have given us your implied consent that your call may be monitored and/or recorded. Also, where we ask you to indicate if you do not wish to be provided with direct marketing material about the Bank’s products and services and you do not provide any such indication, we will assume that you have consented to receiving direct marketing material.
We rely on your implied consent to use and disclose identifying information about you to the Bank’s service providers who assist the Bank in providing you with products and services, such as disclosing your name and account number to a printer to generate your cheque book. Naturally, the confidentiality of your personal information is still maintained, because we prohibit third parties from using your personal information except for the specific purpose for which we have supplied it. If you do not consent to certain uses of personal information, we may not be able to provide you with a particular product or service.
Disclosing to third parties Except where we are required by law or are otherwise entitled, we only disclose personal information to third parties with your express or implied consent. For example, we may disclose personal information to a credit reporting agency, debt collecting agency, an insurer of your mortgage, or your guarantor in certain circumstances. The Bank will not disclose names and addresses to third parties for the purpose of allowing them to directly market their services and products.
We will only transfer your personal information to a third party overseas, for example, to our parent company in Cyprus, if it is necessary to undertake a transaction on your behalf or if we have your consent.
4. Are we allowed to use your tax file number or any other Government identifiers?
We do not use your tax file number (TFN), Medicare number, pension number or any other Government identifier as your account, policy or application number. We only use and disclose these numbers for the purposes required by law, such as disclosing your TFN to the Australian Taxation Office. You may use your pension number or Medicare number to prove your identity when you deal with us.
5. Marketing our products and services
We may use the personal information we have collected from you, from time to time, to identify other of our products and services which we consider may be of interest to you. When we collect personal information from you we will tell you that you will receive direct marketing material unless you indicate otherwise.
We may then contact you to let you know about these products or services. If you do not wish to receive direct marketing information, you can tell us at any time.
6. Keeping your personal information up-to-date
We aim to make sure that the personal information we collect is accurate and up-to-date. This will help us to provide you with the best possible service. We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date whenever we collect or use it.
We will up-date your personal information If you believe that current personal information we hold about you is not accurate or is incomplete or out-of-date, please contact us immediately to enable us to correct it.
The Bank will consider all reasonable requests to correct personal information held which is established to be incorrect. If we are unable to correct the personal information we hold about you, we will provide you with the reasons for our refusal to correct personal information. You also have the right to request that a statement claiming that the information is not accurate, complete or up-to-date be attached to your personal information, if we disagree with your request to correct the information.
7. Gaining access to your information
Generally speaking, you can gain access to your personal information, in which case we will provide this information within a reasonable time. The information which is required to be provided is limited to records held by the Bank which contain your personal information. Such records may include your accounts with the Bank. If you wish to access your personal information, you should submit a request to the Bank in writing identifying the information requested as clearly as possible. We will need to verify your identity before giving you access. The Bank may charge you for its reasonable cost of supplying you with this information. Please refer to our fees and charges booklets, available in branches and corporate centres, for our standard fees and charges.
In certain circumstances, we may not be able to provide you with access to your personal information, such as in the following instances:
- the information would reveal evaluative information connected with our commercially sensitive decision making process;
- the supply of information would have an unreasonable impact upon the privacy of other individuals;
- the information relates to existing or anticipated legal proceedings; or
- the law prevents us from disclosing the information.
If we are unable to tell you what personal information we hold about you, we will provide you with the reasons for denial of access.
8. We store your personal information securely
We take reasonable steps to protect any personal information that we hold from misuse and loss. We also take reasonable steps to protect it from unauthorised access, modification and disclosure. Only users authorised by the Bank can access your personal information and such access is only for purposes for which you have given your consent. Your personal information may be stored in hardcopy documents or as electronic data in the Bank’s software or systems.
The Bank will destroy your personal information in a secure manner and/or de-identify personal information that is no longer required.
We maintain physical security over our paper and electronic data stores and premises, such as locks and security systems. We also maintain computer and network security and other security systems such as user identifiers and passwords to control access to computer systems.
United Trust Security Policy We have comprehensive security procedures and policies documented in our internal security policy. Your personal information will be recorded, amended and deleted only by authorised means. In addition, all employees sign confidentiality agreements as a condition of working for the Bank.
9. Anonymity
You have the option of not identifying yourself when dealing with us, where it is lawful and practicable to do so. For example, you would not need to identify yourself when enquiring about our deposit interest rates.
10. Resolving your privacy issues
We respond quickly to privacy concerns If you believe that the privacy of your personal information has in any way been compromised, you may complain to us. Whilst we undertake to respond as soon as possible to your complaint, we will within 2 working days advise you as to who is responsible for managing your complaint. We will then attempt to resolve the complaint within 10 working days of receipt of your complaint. If this is not possible, we will contact you within that time to provide an estimate as to how long we will need to resolve the complaint.
How to lodge a complaint If you wish to lodge a complaint, contact the staff member or branch that you have been dealing with. We will take responsibility for your complaint at the point where the problem occurs. For additional information regarding our complaints process, please contact any of our branch staff.
11. How to contact the Bank
If you have any questions or require feedback about this privacy policy, you should contact:
Privacy Officer
United Trust Limited
Address: 899 Makati Avenue, manila City 0728, Philippines.
E-mail: [email protected]
Telephone: +1 (940) 489-2169
Fax: +1 (940) 489-2169
We encourage you to check our website regularly for any updates to the United Trust Privacy Policy. Copies of updates to this policy will also be available at any of our branches or corporate centres.